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HMRC internal manual

Stamp Duty Land Tax Manual

Reliefs: Alternative property finance

Land sold to a financial institution and leased to an individual: England & Walesand Northern Ireland: The first transaction FA03/S71A(2)

Relief from stamp duty land tax on the first transaction, purchase of a major interestby the financial institution or undivided share in land, may be claimed by the financialinstitution if the vendor is

  • the individual who enters into the arrangements - the first case
  • another financial institution by whom the interest was acquired under arrangements of the kind mentioned at SDLTM28110, entered into between it and the individual - the second case

Thus, in the first case, the individual may

  • obtain finance against a property owned by them
  • set up a new arrangement with their existing financial institution

In the second case the individual may change financial institutions.

The second case also allows financial institutions to transfer title between themselveswhere the individual is not involved.